MAHARASHTRA STATE ROAD TRANSPORT CORPORATION V. DILIP UTTAM JAYABHAY
COURT: The Supreme Court of India
CORAM: Justices M.R. Shah and B.V. Nagarathna.
DATE OF JUDGMENT: 3 January 2022
In 1992, the respondent, a bus driver, was involved in an accident with a jeep traveling in the other direction. Four passengers lost their lives, and six others suffered critical injuries in this accident. The respondent driver was dismissed from his job following a departmental investigation. In addition, he was prosecuted under Sections 279 and 304(a) of the Indian Penal Code, which resulted in his acquittal since the prosecution could not prove that the driver was solely to blame for the rash and careless driving because of hostile witnesses.
After the acquittal, the respondent challenged his termination before the industrial tribunal, which allowed his reinstatement.
Whether an acquittal in a criminal trial has any bearing or relevance on the disciplinary proceedings?
The Supreme Court held that the order of the Industrial Tribunal was bad in law and the termination based on the departmental investigation was valid. The Court said that the Industrial Tribunal has failed to appreciate the difference between the disciplinary inquiry and the criminal proceeding. The Respondent-Driver was acquitted of the charges under the IPC because the case was sought to be of contributory negligence and but this does not mean the driver was not negligent at all.
The Court highlighted that “As per the cardinal principle of law an acquittal in a criminal trial has no bearing or relevance on the disciplinary proceedings as the standard of proof in both the cases are different and the proceedings operate in different fields and with different objectives.”